Introduction

I-GTM Limited (t/a i-gtm) is committed to protecting the rights and freedoms of data subjects and safely and securely processing their data in accordance with all of our legal obligations.

We hold personal data about our employees, clients, suppliers and other individuals for a variety of business purposes.

This policy sets out how we seek to protect personal data and ensure that our staff understand the rules governing their use of the personal data to which they have access in the course of their work. In particular, this policy requires staff to ensure that the Data Protection Officer (DPO) be consulted before any significant new data processing activity is initiated to ensure that relevant compliance steps are addressed.

Definitions 

Business purposes	The purposes for which personal data may be used by us: Personnel, administrative, financial, regulatory, payroll and business development purposes. Commissioning third parties to perform services for us and in particular booking transport for minors, students and other individuals. Processing data supplied to us by our customers for the purposes of booking travel and communicating all or part of that data to our customers, suppliers or other relevant third party in connection with the services provided. Providing assistance and related services to minors and others as requested in conjunction with our business offering. Communicating news and other relevant information regarding the company’s activities. Reporting events and actions that may have an impact on our ability to provide our service. Compliance with our legal, regulatory and corporate governance obligations and good practice. Gathering information as part of investigations by regulatory bodies or in connection with legal proceedings or requests. Ensuring business policies are adhered to (such as policies covering email, internet use and in particular working with minors). Operational reasons, such as recording transactions, training and quality control, ensuring the confidentiality of commercially sensitive information, security and DBS vetting, credit scoring and checking. Investigating complaints. Checking references, ensuring safe working practices, monitoring and managing staff access to systems and facilities and staff absences, administration and assessments. Monitoring staff conduct, disciplinary matters. Marketing our business. Improving services.
Personal data	‘Personal data’ means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. Personal data we gather may include individuals’ full name, phone number, email address, age, home address, school address, guardianship, nationality, host family name and address, travel and transport arrangements.
Special categories of personal data	Special categories of data include information about an individual’s racial or ethnic origin, political opinions, religious or similar beliefs, trade union membership (or non-membership), physical or mental health or condition, criminal offences, or related proceedings, and genetic and biometric information —any use of special categories of personal data should be strictly controlled in accordance with this policy.
Data controller	‘Data controller’ means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by law.
Data processor	‘Processor’ means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
Processing	‘Processing’ means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Supervisory authority	This is the national body responsible for data protection. The supervisory authority for our organisation is the Information Commissioner’s Office. See our Certificate of Registration

Scope

This policy applies to all staff, who must be familiar with this policy and comply with its terms.

This policy supplements our other policies relating to internet and email use. We may supplement or amend this policy by additional policies and guidelines from time to time. Any new or modified policy will be circulated to staff before being adopted. 

Who is responsible for this policy? 

As our data protection officer (DPO), David J H Williams has overall responsibility for the day-to-day implementation of this policy. You should contact the DPO for further information about this policy if necessary.

David J H Williams,Director I-GTM Ltd.

Tite House, Wardington, Banbury OX17 1SP
Tel. 020 3355 2858
Email: dwilliams@gtmatrix.net 

The principles

I-GTM Ltd. shall comply with the principles of data protection (the Principles) enumerated in the EU General Data Protection Regulation. We will make every effort possible in everything we do to comply with these principles. The Principles are:

1. Lawful, fair and transparent

Data collection must be fair, for a legal purpose and we must be open and transparent as to how the data will be used.

2. Limited for its purpose

Data can only be collected for a specific purpose.

3. Data minimisation

Any data collected must be necessary and not excessive for its purpose.

4. Accurate

The data we hold must be accurate and kept up to date.

5. Retention

We cannot store data longer than necessary.

6. Integrity and confidentiality

The data we hold must be kept safe and secure.

Accountability and transparency

We must ensure accountability and transparency in all our use of personal data. We must show how we comply with each Principle. You are responsible for keeping a written record of how all the data processing activities you are responsible for comply with each of the Principles. This must be kept up to date and must be approved by the DPO.

To comply with data protection laws and the accountability and transparency Principle of GDPR, we must demonstrate compliance. You are responsible for understanding your particular responsibilities to ensure we meet the following data protection obligations :

• Fully implement all appropriate technical and organisational measures
• Maintain up to date and relevant documentation on all processing activities
• Conducting Data Protection Impact Assessments
• Implement measures to ensure privacy by design and default, including:
  • Data minimisation
  • Pseudonymisation
  • Transparency
  • Allowing individuals to monitor processing
  • Creating and improving security and enhanced privacy procedures on an ongoing basis 

Our procedures

Fair and lawful processing

We must process personal data fairly and lawfully in accordance with individuals’ rights under the first Principle. This generally means that we should not process personal data unless the individual whose details we are processing has consented to this happening.

If we cannot apply a lawful basis (explained below), our processing does not conform to the first principle and will be unlawful. Data subjects have the right to have any data unlawfully processed erased.

Controlling data

I-GTM Ltd. is classified as a data controller. We must maintain our appropriate registration with the Information Commissioner’s Office in order to continue lawfully controlling data.

If you are in any doubt about how we handle data, contact the DPO for clarification.

Responsibilities

Our responsibilities

• Analysing and documenting the type of personal data we hold
• Checking procedures to ensure they cover all the rights of the individual
• Identify the lawful basis for processing data
• Ensuring consent procedures are lawful
• Implementing and reviewing procedures to detect, report and investigate personal data breaches
• Store data in safe and secure ways
• Assess the risk that could be posed to individual rights and freedoms should data be compromised

Responsibilities of the Data Protection Officer

• Keeping management updated about data protection responsibilities, risks and issues
• Reviewing all data protection procedures and policies on a regular basis
• Arranging data protection training and advice for all staff members and those included in this policy
• Answering questions on data protection from staff, managers and other stakeholders
• Responding to individuals such as clients and employees who wish to know which data is being held on them by us
• Checking and approving with third parties that handle the company’s data any contracts or agreement regarding data processing

Responsibilities of the IT Manager

• Ensure all systems, services, software and equipment meet acceptable security standards
• Checking and scanning security hardware and software regularly to ensure it is functioning properly
• Researching third-party services, such as cloud services the company is considering using to store or process data

Responsibilities of the Marketing Manager

• Approving data protection statements attached to emails and other marketing copy
• Addressing data protection queries from clients, target audiences or media outlets
• Coordinating with the DPO to ensure all marketing initiatives adhere to data protection laws and the company’s Data Protection Policy

Accuracy and relevance

We will ensure that any personal data we process is accurate, adequate, relevant and not excessive, given the purpose for which it was obtained. We will not process personal data obtained for one purpose for any unconnected purpose unless the individual concerned has agreed to this or would otherwise reasonably expect this.

Individuals may ask that we correct inaccurate personal data relating to them. If you believe that information is inaccurate you should record the fact that the accuracy of the information is disputed and inform the DPO.

Data security

We will keep personal data secure against loss or misuse. Where other organisations process personal data as a service on our behalf, the DPO will establish what, if any, additional specific data security arrangements need to be implemented in contracts with those third party organisations. 

Storing data securely

• In cases when data is stored on printed paper, it should be kept in a secure place where unauthorised personnel cannot access it
• Printed data should be shredded when it is no longer needed
• Data stored on a computer should be protected by strong passwords that are changed regularly. We encourage all staff to use a password manager to create and store their passwords.
• Data stored on CDs or memory sticks must be encrypted or password protected and locked away securely when they are not being used
• The DPO must approve any cloud service used to store data
• Data stored using a cloud-based service, whether that be static file storage or as part of a Software as a Service application will be encrypted at rest and in transmission. 
• Cloud service providers used by I-GTM will be compliant with the requirements of GDPR.
• Data should be regularly backed up in line with the company’s backup procedures
• All possible technical measures must be put in place to keep data secure 

Data retention

We must retain personal data for no longer than is necessary. What is necessary will depend on the circumstances of each case, taking into account the reasons that the personal data was obtained, but should be determined in a manner consistent with our data retention guidelines.

Transferring data internationally

There are restrictions on international transfers of personal data. We will not transfer personal data abroad, or anywhere else outside of normal rules and procedures without express permission from the DPO.

Rights of individuals

Individuals have rights to their data which we must respect and comply with to the best of our ability. We must ensure individuals can exercise their rights in the following ways:

1. Right to be informed

Providing privacy notices which are concise, transparent, intelligible and easily accessible, free of charge, that are written in clear and plain language, particularly if aimed at children.

Keeping a record of how we use personal data to demonstrate compliance with the need for accountability and transparency.

1. Right of access

Enabling individuals to access their personal data and supplementary information Allowing individuals to be aware of and verify the lawfulness of the processing activities

1. Right to rectification

We must rectify or amend the personal data of the individual if requested because it is inaccurate or incomplete.

This must be done without delay, and no later than one month. This can be extended to two months with permission from the DPO.

1. Right to erasure

We must delete or remove an individual’s data if requested and there is no compelling reason for its continued processing.

1. Right to restrict processing

We must comply with any request to restrict, block, or otherwise suppress the processing of personal data.

We are permitted to store personal data if it has been restricted, but not process it further. We must retain enough data to ensure the right to restriction is respected in the future.

1. Right to data portability

We must provide individuals with their data so that they can reuse it for their own purposes or across different services.

We must provide it in a commonly used, machine-readable format, and send it directly to another controller if requested.

1. Right to object

We must respect the right of an individual to object to data processing based on legitimate interest or the performance of a public interest task.

We must respect the right of an individual to object to direct marketing, including profiling. We must respect the right of an individual to object to processing their data for scientific and historical research and statistics.

1. Rights in relation to automated decision making and profiling

We must respect the rights of individuals in relation to automated decision making and profiling.

Individuals retain their right to object to such automated processing, have the rationale explained to them, and request human intervention.

Subject Access Requests

What is a subject access request?

An individual has the right to receive confirmation that their data is being processed, access to their personal data and supplementary information which means the information which should be provided in a privacy notice.

How we deal with subject access requests

We must provide an individual with a copy of the information they request, free of charge. This must occur without delay, and within one month of receipt. We endeavour to provide data subjects access to their information in commonly used electronic formats, and where possible, provide direct access to the information through a remote accessed secure system.

If complying with the request is complex or numerous, the deadline can be extended by two months, but the individual must be informed within one month. You must obtain approval from the DPO before extending the deadline.

We can refuse to respond to certain requests, and can, in circumstances of the request being manifestly unfounded or excessive, charge a fee. If the request is for a large quantity of data, we can request the individual specify the information they are requesting. This can only be done with express permission from the DPO.

Once a subject access request has been made, you must not change or amend any of the data that has been requested. Doing so is a criminal offence.

Data portability requests

We must provide the data requested in a structured, commonly used and machine-readable format. This would normally be a CSV file, although other formats are acceptable. We must provide this data either to the individual who has requested it, or to the data controller they have requested it be sent to. This must be done free of charge and without delay, and no later than one month. This can be extended to two months for complex or numerous requests, but the individual must be informed of the extension within one month and you must receive express permission from the DPO first.

Right to erasure

What is the right to erasure?

Individuals have a right to have their data erased and for processing to cease in the following circumstances:

• Where the personal data is no longer necessary in relation to the purpose for which it was originally collected and / or processed
• Where consent is withdrawn
• Where the individual objects to processing and there is no overriding legitimate interest for continuing the processing
• The personal data was unlawfully processed or otherwise breached data protection laws
• To comply with a legal obligation
• The processing relates to a child

How we deal with the right to erasure

We can only refuse to comply with a right to erasure in the following circumstances:

• To exercise the right of freedom of expression and information
• To comply with a legal obligation for the performance of a public interest task or exercise of official authority
• For public health purposes in the public interest
• For archiving purposes in the public interest, scientific research, historical research or statistical purposes
• The exercise or defence of legal claims 

If personal data that needs to be erased has been passed onto other parties or recipients, they must be contacted and informed of their obligation to erase the data. If the individual asks, we must inform them of those recipients.

The right to object

Individuals have the right to object to their data being used on grounds relating to their particular situation. We must cease processing unless:

• We have legitimate grounds for processing which override the interests, rights and freedoms of the individual.
• The processing relates to the establishment, exercise or defence of legal claims.

We must always inform the individual of their right to object at the first point of communication, i.e. in the privacy notice. We must offer a way for individuals to object online.

The right to restrict automated profiling or decision making

We may only carry out automated profiling or decision making that has a legal or similarly significant effect on an individual in the following circumstances:

• It is necessary for the entry into or performance of a contract.
• Based on the individual’s explicit consent.
• Otherwise authorised by law.

In these circumstances, we must:

• Give individuals detailed information about the automated processing.
• Offer simple ways for them to request human intervention or challenge any decision about them.
• Carry out regular checks and user testing to ensure our systems are working as intended.

Third parties

Using third party controllers and processors

As a data controller, we must have written contracts in place with any third party data controllers that we use. The contract must contain specific clauses which set out our and their liabilities, obligations and responsibilities.

As a data controller, we must only appoint controllers and/or data processors who can provide sufficient guarantees under GDPR and that the rights of data subjects will be respected and protected.

Contracts

Our contracts must comply with the standards set out by the ICO and, where possible, follow the standard contractual clauses which are available. Our contracts with data controllers and/or data processors must set out the subject matter and duration of the processing, the nature and stated purpose of the processing activities, the types of personal data and categories of data subject, and the obligations and rights of the controller.

At a minimum, our contracts must include terms that specify:

• Acting only on written instructions
• Those involved in processing the data are subject to a duty of confidence
• Appropriate measures will be taken to ensure the security of the processing
• Sub-processors will only be engaged with the prior consent of the controller and under a written contract
• The controller will assist the processor in dealing with subject access requests and allowing data subjects to exercise their rights under GDPR
• The processor will assist the controller in meeting its GDPR obligations in relation to the security of processing, notification of data breaches and implementation of Data Protection Impact Assessments
• Delete or return all personal data at the end of the contract
• Submit to regular audits and inspections, and provide whatever information necessary for the controller and processor to meet their legal obligations.
• Nothing will be done by either the controller or processor to infringe on GDPR.

Criminal offence data

Criminal record checks

Any criminal record checks are justified by law. Criminal record checks cannot be undertaken based solely on the consent of the subject. We cannot keep a comprehensive register of criminal offence data. All data relating to criminal offences is considered to be a special category of personal data and must be treated as such. You must have approval from the DPO prior to carrying out a criminal record check.

Audits, monitoring and training

Data audits

Regular data audits to manage and mitigate risks will inform the data register. This contains information on what data is held, where it is stored, how it is used, who is responsible and any further regulations or retention timescales that may be relevant. You must conduct a regular data audit as defined by the DPO and normal procedures.

Monitoring

Everyone must observe this policy. The DPO has overall responsibility for this policy. I-GTM Ltd. will keep this policy under review and amend or change it as required. You must notify the DPO of any breaches of this policy. You must comply with this policy fully and at all times.

Training

You will receive adequate training on provisions of data protection law specific for your role. You must complete all training as requested. If you move role or responsibilities, you are responsible for requesting new data protection training relevant to your new role or responsibilities.

If you require additional training on data protection matters, contact the DPO.

Reporting breaches

Any breach of this policy or of data protection laws must be reported as soon as practically possible. This means as soon as you have become aware of a breach. I-GTM Ltd. has a legal obligation to report any data breaches to the ICO within 72 hours.

All members of staff have an obligation to report actual or potential data protection compliance failures. This allows us to:

• Investigate the failure and take remedial steps if necessary
• Maintain a register of compliance failures
• Notify the ICO of any compliance failures that are material either in their own right or as part of a pattern of failures

Any member of staff who fails to notify of a breach, or is found to have known or suspected a breach has occurred but has not followed the correct reporting procedures will be liable to disciplinary action.

Failure to comply

We take compliance with this policy very seriously. Failure to comply puts both you and the organisation at risk.

The importance of this policy means that failure to comply with any requirement may lead to disciplinary action under our procedures which may result in dismissal.

If you have any questions or concerns about anything in this policy, do not hesitate to contact the DPO.